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Coding for Transitional Care Management

Coding Corner

The information provided here applies to Medicare coding. Be sure to check with your Medicare Administrative Contractor (MAC) for additional information and clarification on these and other items. You should also contact your local insurance carriers to determine if private insurers follow Medicare's lead on all coding matters.

Coding for Transitional Care Management
A number of topics were explored at a coding session held at the ACOI’s 2014 Annual Convention and Scientific Sessions in October. One particular area of interest raised by the attendees was a discussion of the proper coding for Transitional Care Management (TCM).  TCM includes services provided to a patient whose medical and/or psychosocial condition requires moderate- or high-complexity medical-decision making while transitioning care from an inpatient hospital setting to a community setting.  (See June 2013, CMS ICN 908628 for additional details.)
In defining TCM, the Centers for Medicare and Medicaid Services (CMS) has indicated that the TCM code is for providers providing or overseeing the management and coordination of services for a patient for 30 days, addressing as needed, their medical conditions, psychosocial needs and activity supporting daily living.

Clarity as to who can order or initiate TCM remains elusive as there is no clear definition at this time.   An October FAQ issued by CMS states that the initial interactive contact must be more than a hospital or a family member calling to make an appointment.  According to the FAQ, it must be an “interactive exchange of information.”  Absent additional guidance by CMS, practices must determine if their initiation of TCM meets this “interactive exchange of information” requirement for Medicare patients.